IRS releases updated QI agreement providing guidance for QIs under FATCA and Chapter 3

Size: px
Start display at page:

Download "IRS releases updated QI agreement providing guidance for QIs under FATCA and Chapter 3"

Transcription

1 IRS releases updated QI agreement providing guidance for QIs under FATCA and Chapter 3 July 3, 2014 In brief On June 27, 2014, the Internal Revenue Service (IRS) released Revenue Procedure which provides guidance on the reporting, withholding, account documentation and registration requirements for a non-us intermediary entering into or renewing a qualified intermediary (QI) agreement. The issuance of a new QI agreement has been anticipated, and the majority of the changes from the existing QI agreement reflect the reporting and withholding requirements set forth under the provisions of the Foreign Account Tax Compliance Act (FATCA). The new QI agreement coordinates account documentation, withholding, and reporting requirements under QI with those under FATCA. Finally, as expected, the external audit procedures in the previous QI agreement have been replaced by a responsible officer concept which requires periodic compliance certifications and mandatory periodic reviews of an internal compliance program. PwC Observation: QIs should immediately assess the impact of the revisions to the QI agreement on their current QI operations, with a specific focus on outsourced functions, and implement changes where required. The new procedures should be aligned with current FATCA compliance programs. Special attention should be applied to the specific withholding requirements, particularly in the intergovernmental agreement (IGA) context. In detail The QI agreement is intended to set out how a non-us intermediary should assume the withholding and reporting obligations for payments of US source income (including interest, dividends, royalties, etc.) made to its account holders or payees. The revised QI agreement describes the FATCA requirements that apply to a QI that is also an FFI. An FFI that has entered into a QI agreement is subject to the FATCA requirements for all accounts that it maintains irrespective of whether the FFI is acting as a QI with respect to the account. When an FFI acts as a QI with respect to an account that it maintains, the FFI must comply with its FATCA obligations, unless such FATCA obligations have been explicitly modified in the QI agreement. Legal Entities Impacted Entities eligible to execute a QI agreement A QI agreement may be entered into by foreign financial institutions (FFIs), foreign clearing organizations, and foreign branches of US financial institutions (USFIs) or US clearing organizations. In addition, the revised QI agreement clarifies that in certain cases, a non-financial foreign entity (NFFE) 1

2 may enter into a QI agreement (without any need for a rider) and describes the specific requirements for such an entity to the extent they differ from the requirements applicable to a QI that is an FFI. Furthermore, while not all FFIs must enter into a QI agreement, for those institutions that do enter into a QI agreement, compliance with FATCA has become a prerequisite to becoming a QI. Type of Entity FFI A certified deemedcomplaint FFI (including a nonreporting IGA FFI) A central bank of issue A foreign branch of a USFI An NFFE acting on behalf of its shareholders An NFFE acting on behalf of persons other than its shareholders Can execute a QI agreement when it: is able and agrees to satisfy the requirements and obligations of: 1. a participating FFI (PFFI) (including a reporting Model 2 FFI), 2. a registered deemed-compliant FFI (including a reporting Model 1 FFI and a nonreporting Model 2 FFI treated as registered deemed-complaint), 3. a registered deemed-compliant Model 1 IGA FFI (which includes an FFI treated as a deemed-compliant FFI under an applicable Model 1 IGA that is subject to similar due diligence and reporting requirements with respect to U.S. accounts as those applicable to a registered deemed-compliant FFI under Treasury Regulation (f)(1)), or 4. a limited FFI, for a transitional period. meets the requirements and agrees to assume the FATCA obligations of an FFI (see above) with respect to all accounts that it maintains. This includes accounts that the FFI does not intend to designate as accounts for which it will act as a QI. meets the criteria and agrees to assume the respective obligations of a PFFI (including a reporting Model 2 FFI) or a registered deemedcompliant FFI (including a reporting Model 1 FFI) with respect to any account that it maintains and that is held in connection with a commercial financial activity and for which it receives a withholdable payment. is a reporting Model 1 FFI or it agrees to assume the requirements and obligations of a PFFI (including a reporting Model 2 FFI). meets the criteria for treatment as a direct reporting NFFE and agrees to assume the respective obligations of such treatment. satisfies the FATCA withholding and reporting requirements that generally apply to withholding agents. An entity that is a territory financial institution (territory FI) or a nonparticipating FFI may not apply for a QI agreement. While QI and FATCA remain distinct requirements, the QI status needs to be aligned to the FATCA status. Thus, a QI that assumes primary withholding obligations for Chapter 3 must also assume primary withholding obligations for FATCA (i.e., Chapter 4). 2

3 PwC Observation: As a result of the QI eligibility rules, it appears that an existing QI wishing to maintain its QI status that qualifies for a FATCA status with reduced due diligence obligations, such as a certified deemed-compliant FFI, may be required to perform a higher level of due diligence than is generally required under FATCA, if it wishes to maintain its QI status. Consistent with the previous QI agreement, a QI may act as a QI only in a jurisdiction with IRS approved know-your-customer-rules. Link to List of Approved jurisdictions Treatment of certain partnerships and trusts The revised QI agreement includes the joint account and agency options of the existing QI agreement, which allow a QI to enter into an agreement with a nonwithholding foreign partnership or nonwithholding foreign trust to apply simplified documentation, withholding, and reporting requirements for payments made to these entities. However, there are specifications on the FATCA statuses required of the partnerships and trusts as well as their partners, owners, and beneficiaries in order to apply such procedures. Effective date of QI agreement The revised QI agreement has an effective date of on or after June 30, The following table outlines the general effective dates based on application and renewal dates: Type of Entity An FFI, an NFFE acting as a QI on behalf of its shareholders, or an NFFE that is a sponsoring entity A QI that is an NFFE that is not acting on behalf of its shareholders and is not a sponsoring entity An NFFE that is not acting on behalf of its shareholders and is not a sponsoring entity Application or Renewal Date Applies before June 30, 2014 Applies on or after June 30, 2014 Renews on or before June 30, 2014 Renews after June 30, 2014 Applies to obtain QI status QI Effective Date June 30, 2014, provided that it is also issued a global intermediary identification number (GIIN) before June 30 The date its GIIN is issued June 30, 2014 An effective date consistent with the date of renewal provided in the IRS approval notice The date that it is issued a QI employer identification number A QI that has submitted a QI application before July 31, 2014 and is approved during calendar year 2014 may act as a QI in accordance with the existing QI agreement from January 1, 2014 through June 30, PwC Observation: It would appear that if an entity did not apply for QI status or apply to renew QI status prior to June 30, 2014, there will be a gap in QI status from July 1, 2014 through the time QI status is approved or renewed by the IRS. For example, an existing QI that applies for renewal after June 30, 2014 would have had its existing agreement expire on June 30, 2014 and thus would have a gap in coverage from July 1, 2014 through the date its GIIN is issued or the date of renewal provided in the IRS approval notice. Similarly, it would appear that an entity that applies for QI

4 status prior to July 31, 2014 will have QI status from January 1, 2014 through June 30, 2014, NQI status from July 1, 2014 through the date of approval, and QI status from the date of approval forward. It is not clear if this gap particularly in the second instance is intentional. Due Diligence Procedures QI s documentation requirements for Chapters 3 and 4 purposes The revised QI agreement updates the documentation requirements under the existing QI agreement to reference the documentation requirements applicable to a QI with respect to payees to which it makes withholdable payments. Furthermore, the QI agreement updates the due diligence requirements applicable to establish an FFI s FATCA status with respect to a QI that is: a PFFI (including a Model 2 FFI), a registered deemed-compliant FFI (including a reporting Model 1 FFI or a nonreporting Model 2 FFI treated as registered deemed-compliant), or a registered deemed-compliant Model 1 FFI. QIs documenting their direct account holders for purposes of Chapters 3 and 61 are permitted under the QI agreement to use documentary evidence permitted under the QI s know-your-customer rules. The requirements relating to the use of documentary evidence do not apply to an NFFE acting as a QI, because the entity is required to obtain Forms W-8 and W-9 from its account holders. The QI agreement also incorporates changes to the documentation requirements applicable to a QI for purposes of Chapter 3 consistent with temporary regulations under Section QI s presumption rules and reliable association of payments The revised QI agreement modifies the presumption rules of the previous QI agreement to coordinate with the presumption rules of FATCA as well as with the revisions to the presumption rules made in the temporary coordinating regulations. The QI agreement also revises the circumstances in which a QI can avoid application of the presumption rules by modifying the rules for when the QI can reliably associate a payment with valid documentation and the rules for how intermediaries and flow-through entities may provide withholding statements to withholding agents (including QIs) for FATCA purposes. Reporting Obligations QI s reporting on Form 1042-S The updated QI agreement substantially modifies a QI s Form 1042-S reporting requirements by incorporating certain FATCA reporting obligations with respect to intermediaries and flow-through entities that provide FATCA withholding rate pool information to the QI on withholding statements. The revised rules provide that a withholding agent may use a single Form 1042-S to report information required under both Chapters 3 and 4 with respect to a withholdable payment of US source FDAP income subject to withholding under Chapter 4 and for which a credit against the beneficial owner s Chapter 3 liability, if any, may be claimed. PwC Observation: In practice, the crediting of FATCA-withholding towards Chapter 3 liability seems to be the rule and only one Form 1042-S is required. The revised requirements also reference the Form 1042-S requirements of a QI with respect to its direct account holders when FATCA withholding applies, and allow the QI to file Forms 1042-S with respect to a Chapter 4 withholding rate pool. 4

5 QI's 1042 reporting and reconciliation of Chapter 3 and Chapter 4 A QI must annually file Form 1042 reconciling the taxes withheld for Chapter 3 and Chapter 4. Form 1042 includes over- and underwithholding adjustments for Chapters 3 and 4, provided that all pre-conditions of the adjustment procedures are met within a rather short time frame, i.e. until the due date of Form 1042 on March 15 of the following calendar year. This timing is consistent with the prior version of the QI agreement and the Chapter 3 regulations. QI's FATCA U.S. Account and Form 1099 Reporting FATCA reporting is now part of the QI agreement and all QIs have to adhere to this obligation; however, the updated QI agreement provides for certain alignments between FATCA and QI reporting. Thus, to the extent that a QI has assumed Form 1099 reporting responsibilities, and the QI reports such account for purposes of FATCA as a U.S. reportable account, the QI is generally not required to file Forms 1099 for such account. Reporting under Section 1472 Regardless of whether a foreign intermediary is an FFI or did not assume a withholding obligation under the QI agreement, the QI will be required to assume a reporting obligation with respect to passive NFFEs that have substantial US owners (or controlling persons that are specified US persons) and will not be required to provide specific payee information to other withholding agents for purposes of the reporting under Section A QI will also be required to act as a direct reporting NFFE for purposes of reporting its substantial US owners under Section 1472 when it acts as a QI on behalf of its shareholders 5 PwC Observation: The updates to the QI agreement regarding the alignment between FATCA and QI reporting allow QIs to continue current procedures to satisfy certain FATCA requirements, if they wish to do so, and also relieve QIs of having to perform duplicative reporting on certain accounts. Withholding Obligations Withholding responsibilities The withholding provisions under the updated QI agreement have been enhanced to incorporate FATCA withholding obligations, and the updated QI agreement states that a QI is a withholding agent for purposes of FATCA and subject to the withholding and reporting provisions applicable to withholding agents under sections 1471 and 1472 with respect to its accounts. Consistent with the previous QI agreement and with FATCA, withholding only applies to US source FDAP (fixed and determinable annual and periodical income) income and certain equivalents thereof. The updated QI agreement incorporates the changes previously seen in IRS notices regarding the satisfaction of withholding on recalcitrant account holders by performing backup withholding. QIs can simply impose FATCA withholding on recalcitrant account holders instead of backup withholding. In either event, withholding is only applied once to payments made to a recalcitrant account holder (i.e., FATCA or backup withholding). PwC Observation: The updated QI agreement now provides clarity on the FATCA withholding obligations of a QI which is an FFI, which had been unclear under the Model 1 IGA regime. Under the updated QI agreement, a QI is a withholding agent under Chapters 3 and 4 for amounts that it pays to its account holders. This, however, creates uncertainty on the scope of the withholding obligations for a QI in a Model 1 IGA jurisdiction, where the IGA limits the withholding to NPFFIs. The new QI agreement further clarifies that a QI must comply with its FATCA requirements as a Model 1 IGA FFI with respect to all financial accounts that it maintains, irrespective of whether an

6 account is designated as an account for which it will act as a QI, thus, creating more uncertainty as to the scope of withholding, which is currently limited in a Model 1 context to those accounts for which a QI currently withholds on under the QI regime. QIs acting as qualified securities lenders (QSLs) The revised QI agreement permits a QI to act as a QSL with respect to payments of US source substitute dividends as long as it acts as a QSL with respect to all US source substitute dividends it receives as an intermediary or dealer. Compliance Obligations QI s compliance procedures The new QI agreement substantially modifies QI audit requirements. A QI is required to designate a responsible officer with authority to establish an internal compliance program including policies, procedures and processes sufficient for a QI to satisfy the documentation, reporting and withholding requirements under the QI agreement. The responsible officer is also required to make compliance certifications to the IRS every three calendar years, starting with the period ending on the third full calendar year that the QI agreement is in effect. Furthermore, the responsible officer must designate an auditor that will perform a periodic review of the QI s compliance with the QI agreement and its FATCA requirements. Under the new QI agreement it is possible to appoint either an internal or an external auditor. PwC Observation: Through the QI agreement, Model 1 IGA FFIs that are QIs will now have to implement a comprehensive responsible officer compliance program to enable periodic certification. Furthermore, it remains to be seen whether financial institutions will continue to rely on external auditors to assist with the fulfillment of these compliance obligations. Events of default An event of default occurs if a QI fails to perform any material duty or obligation required under the QI agreement and the responsible officer had actual knowledge or should have known the facts relevant to the failure. Specific cases are listed in the QI agreement. Term of the revised QI agreement The revised QI agreement will expire, unless otherwise previously terminated, on December 31, 2016, which is consistent with the term of the FFI agreement. PwC Observation: On January 1, 2017, withholding on payments of gross proceeds and foreign passthru payments is expected to enter into force. These new requirements coincide with the December 31, 2016 expiration of the QI and participating FFI agreements. QI Agreement Application Procedures Application for QI status The Revenue Procedure describes the application procedures for becoming a QI or renewing a QI agreement. Once a prospective QI, has an approved QI application it will be instructed to register through the FATCA registration website to obtain its FATCA status and register as a QI. Except as otherwise provided in future guidance, the IRS will not enter into a QI agreement with an FFI that provides for the 6

7 use of documentary evidence obtained under a jurisdiction s know-your-customer rules if the IRS has not approved the know your customer practices and procedures for opening accounts. The IRS intends to update the online FATCA registration website to allow prospective QIs to submit a QI application electronically; however, until this update is made, an entity wishing to become a QI must submit a paper application. Key Takeaways With July 1 as the effective date for many FATCA obligations, the Revenue Procedure provides guidance which QIs are required to implement in a short period of time. While many of the provisions for FFIs were expected, compliance programs may still need to be expanded to include certain additional requirements arising from the QI agreement. The bigger challenges may apply to certified deemed-compliant FFIs that are QIs, because of the requirement to comply with the enhanced due diligence requirements for all of the accounts they maintain. Let s talk For more information on how the new QI agreement might impact your business, please contact a member of the PwC s Global Information Reporting Network. To view contacts for over 70 countries worldwide, click here. Additional information For other information regarding FATCA and QI guidance and implementation, please click here for the Global Information Reporting thought leadership archive PricewaterhouseCoopers LLP, a Delaware limited liability partnership. All rights reserved. PwC refers to the United States member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see for further details. SOLICITATION This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors. 7

This notice provides guidance to foreign financial institutions (FFIs) entering into

This notice provides guidance to foreign financial institutions (FFIs) entering into Part III Administrative, Procedural, and Miscellaneous FFI agreement for Participating FFI and Reporting Model 2 FFI Notice 2013-69 SECTION I. Purpose. This notice provides guidance to foreign financial

More information

US FATCA FAQ and Glossary of FATCA terms

US FATCA FAQ and Glossary of FATCA terms US FATCA FAQ and Glossary of FATCA terms These FAQs are intended to aid you in your understanding how FATCA affects your relationship with UBS. This is not intended as tax advice. If you are uncertain

More information

Instructions for the Requester of Forms W 8BEN, W 8BEN E, W 8ECI, W 8EXP, and W 8IMY (Rev. July 2014)

Instructions for the Requester of Forms W 8BEN, W 8BEN E, W 8ECI, W 8EXP, and W 8IMY (Rev. July 2014) Instructions for the Requester of Forms W 8BEN, W 8BEN E, W 8ECI, W 8EXP, and W 8IMY (Rev. July 2014) Section references are to the Internal Revenue Code unless otherwise noted. Future developments. For

More information

How does the recent FATCA guidance affect asset managers?

How does the recent FATCA guidance affect asset managers? from Asset Management How does the recent FATCA guidance affect asset managers? April 10, 2014 In brief On February 20, 2014, the US Department of the Treasury (Treasury) and the Internal Revenue Service

More information

Further Guidance on the Implementation of FATCA and Related Withholding Provisions

Further Guidance on the Implementation of FATCA and Related Withholding Provisions Further Guidance on the Implementation of FATCA and Related Withholding Provisions Notice 2014-33 I. PURPOSE This notice announces that calendar years 2014 and 2015 will be regarded as a transition period

More information

U.S. Tax Services Stewart H. Patton 610-0689 stewart@ustax.bz. FATCA Overview. March 2014

U.S. Tax Services Stewart H. Patton 610-0689 stewart@ustax.bz. FATCA Overview. March 2014 U.S. Tax Services Stewart H. Patton 610-0689 stewart@ustax.bz FATCA Overview March 2014 FATCA Terminology FATCA: The U.S. Foreign Account Tax Compliance Act, added by the HIRE Act of 2010. FATCA added

More information

How do the final FATCA regulations affect asset managers?

How do the final FATCA regulations affect asset managers? How do the final FATCA regulations affect asset managers? February 6, 2013 In brief The long-awaited final Foreign Account Tax Compliance Act (FATCA) regulations have arrived and, while much analysis still

More information

Sight FATCA. line of. Frequently asked questions. table of contents. November 2, 2012

Sight FATCA. line of. Frequently asked questions. table of contents. November 2, 2012 line of Sight FATCA Frequently asked questions FOR INSTITUTIONAL INVESTORS table of contents November 2, 2012 PART I PROPOSED REGULATIONS and IRS Announcement OVERVIEW 1. What is the objective of the Foreign

More information

Analysis of FATCA Regulations for Foreign Financial Institutions

Analysis of FATCA Regulations for Foreign Financial Institutions Analysis of FATCA Regulations for Foreign Financial Institutions Withholding, Information Reporting February 2014 kpmg.com FATCA - Regulations on information reporting by foreign financial institutions;

More information

IRS regulations The Foreign Account Tax Compliance Act (FATCA) and its impact on the US foreign withholding tax and reporting system

IRS regulations The Foreign Account Tax Compliance Act (FATCA) and its impact on the US foreign withholding tax and reporting system IRS regulations The Foreign Account Tax Compliance Act (FATCA) and its impact on the US foreign withholding tax and reporting system What is FATCA? The Foreign Account Tax Compliance Act (FATCA) is a new

More information

Foreign Account Tax Compliance Act FATCA Onboarding Requirements for Payees U.S. Financial Institutions

Foreign Account Tax Compliance Act FATCA Onboarding Requirements for Payees U.S. Financial Institutions Paris New York London Rome Milan Casablanca Dubai Amsterdam Brussels Hong Kong Singapore Foreign Account Tax Compliance Act FATCA Onboarding Requirements for Payees U.S. Financial Institutions June 13,

More information

The Foreign Account Tax Compliance Act (FATCA)

The Foreign Account Tax Compliance Act (FATCA) The Foreign Account Tax Compliance Act (FATCA) Applying FATCA to Funds and other Collective Investment Vehicles Jonathan Sambur Partner + 1 202 263-3256 jsambur@mayerbrown.com February 2013 Mayer Brown

More information

UPDATED INFORMATION ON USE OF FORM W-8IMY (REVISION DATE FEBRUARY 2006) BEFORE JANUARY 1, 2015

UPDATED INFORMATION ON USE OF FORM W-8IMY (REVISION DATE FEBRUARY 2006) BEFORE JANUARY 1, 2015 UPDATED INFORMATION ON USE OF FORM W-8IMY (REVISION DATE FEBRUARY 2006) BEFORE JANUARY 1, 2015 This Form W-8IMY (revision date April 2014) reflects the changes made in the Foreign Account Tax Compliance

More information

SIGHT FATCA. line of FREQUENTLY ASKED QUESTIONS FOR FUND MANAGERS TABLE OF CONTENTS. July 2012 OVERVIEW... 2

SIGHT FATCA. line of FREQUENTLY ASKED QUESTIONS FOR FUND MANAGERS TABLE OF CONTENTS. July 2012 OVERVIEW... 2 line of SIGHT FATCA FREQUENTLY ASKED QUESTIONS FOR FUND MANAGERS TABLE OF CONTENTS July 2012 OVERVIEW... 2 NORTHERN TRUST S ROLES AND RESPONSIBILITIES... 7 PREVENTING FATCA WITHHOLDING... 8 A PARTICIPATING

More information

FATCA FAQs: Frequently asked questions on the Foreign Account Tax Compliance

FATCA FAQs: Frequently asked questions on the Foreign Account Tax Compliance www.pwc.com/us/fatca July 2011 FATCA FAQs: Frequently asked questions on the Foreign Account Tax Compliance Act 1. What is FATCA? FATCA is an acronym for The Foreign Account Tax Compliance Act (FATCA)

More information

IRS Releases Updated Qualified Intermediary (QI) Agreement

IRS Releases Updated Qualified Intermediary (QI) Agreement International Bank Tax Newsletter IRS Releases Updated Qualified Intermediary (QI) Agreement Authored by Melinda T. Schmidt On June 27, 2014, the Internal Revenue Service (IRS) released Revenue Procedure

More information

The Impact of FATCA on U.S. and Non-U.S. Private Equity & Hedge Funds Closing the distance

The Impact of FATCA on U.S. and Non-U.S. Private Equity & Hedge Funds Closing the distance The Impact of FATCA on U.S. and Non-U.S. Private Equity & Hedge Funds Closing the distance Global Financial Services Industry Overview The Foreign Account Tax Compliance Act ( FATCA ) regime signifies

More information

Foreign Account Tax Compliance Act ( FATCA )

Foreign Account Tax Compliance Act ( FATCA ) Chio Lim Audit Tax Advisory Tax Update Foreign Account Tax Compliance Act ( FATCA ) 2 May 2014 Contacts: Cindy Lim Partner, International Tax Division T +65 6594 7852 cindylim@rsmchiolim.com.sg Chow Khen

More information

FATCA Overview for Non-U.S. Insurance Companies

FATCA Overview for Non-U.S. Insurance Companies Stewart Patton U.S. Tax Services P.O. Box 2651 Belize City, Belize www.ustax.bz +501 610-0689 (Belize phone number) (312) 675-8571 (U.S. VOIP number) stewart.patton1 (Skype ID) stewart@ustax.bz FATCA Overview

More information

IRS Issues Final FATCA Regulations

IRS Issues Final FATCA Regulations IRS Issues Final FATCA Regulations The United States Internal Revenue Service (IRS) has issued long-awaited final regulations (the Final Regulations) under the Foreign Account Tax Compliance Act (FATCA).

More information

BURT, STAPLES & MANER, LLP SUITE 850 1250 EYE STREET, NW WASHINGTON, DC 20005-3922 PHONE (202)783-1500 - FACSIMILE (202)783-1523 www.bsmlegal.

BURT, STAPLES & MANER, LLP SUITE 850 1250 EYE STREET, NW WASHINGTON, DC 20005-3922 PHONE (202)783-1500 - FACSIMILE (202)783-1523 www.bsmlegal. BURT, STAPLES & MANER, LLP SUITE 850 1250 EYE STREET, NW WASHINGTON, DC 20005-3922 PHONE (202)783-1500 - FACSIMILE (202)783-1523 www.bsmlegal.com TO: FROM: RE: Distribution Burt, Staples & Maner, LLP Final

More information

Foreign Account Tax Compliance Act (FATCA) Frequently Asked Questions

Foreign Account Tax Compliance Act (FATCA) Frequently Asked Questions Foreign Account Tax Compliance Act (FATCA) Frequently Asked Questions For Momentum Retail (excluding Momentum Wealth International) General FATCA questions 1. What is FATCA? FATCA is the acronym for the

More information

FATCA -- Overview and Onboarding

FATCA -- Overview and Onboarding IIB Annual Seminar on U.S. Taxation of International Banks June 17-18, 2014 FATCA -- Overview and Onboarding Chip Collins, UBS AG (Moderator) John Sweeney, IRS Tara Ferris, IRS Jon Lakritz, PwC Danielle

More information

FATCA Regulations Training Session #3

FATCA Regulations Training Session #3 Transaction Services July 2013 FATCA Regulations Training Session #3 Update on Changes to New Account Due Diligence Based on Final Regulations Debbie Mercer-Miller Director and U.S. Securities Country

More information

Foreign Account Tax Compliance Act (FATCA) Intergovernmental Agreement Model 1 Latest Updates and Requirements

Foreign Account Tax Compliance Act (FATCA) Intergovernmental Agreement Model 1 Latest Updates and Requirements Foreign Account Tax Compliance Act (FATCA) Intergovernmental Agreement Model 1 Latest Updates and Requirements - Regulatory Timeline - Overview of Requirements - Registration Process Naidira Alemova-Goeres

More information

FATCA The Foreign Account Tax Compliance Act

FATCA The Foreign Account Tax Compliance Act FATCA The Foreign Account Tax Compliance Act July 2012 July 2012 Table of Contents 1. Classification 2 2. Due Diligence 7 3. Withholding Payments 14 4. Reporting 21 What You Need to Take Away From This

More information

Fiduciary and Investment Risk Management Association 28 th National Risk Management Training Conference

Fiduciary and Investment Risk Management Association 28 th National Risk Management Training Conference Fiduciary and Investment Risk Management Association 28 th National Risk Management Training Conference Foreign Account Tax Compliance Act: Considerations for Trusts April 30, 2014 Michael Shepard Principal

More information

The widespread reach of FATCA How will it affect your business?

The widespread reach of FATCA How will it affect your business? www.pwc.com/us/fatca The widespread reach of FATCA How will it affect your business? August 2013 Contents The short answer 1 Now is the right time to learn more and take action 2 What are some specific

More information

Application Procedures for Qualified Intermediary Status Under Section 1441; Final Qualified Intermediary Withholding Agreement

Application Procedures for Qualified Intermediary Status Under Section 1441; Final Qualified Intermediary Withholding Agreement Part III Administrative, Procedural, and Miscellaneous Application Procedures for Qualified Intermediary Status Under Section 1441; Final Qualified Intermediary Withholding Agreement Rev. Proc 2000-12

More information

FATCA: A Portfolio Manager s Guide to Navigating Uncharted Waters

FATCA: A Portfolio Manager s Guide to Navigating Uncharted Waters FATCA: A Portfolio Manager s Guide to Navigating Uncharted Waters Michael Friedman, Tax Partner, McMillan LLP Carl Irvine, Tax Principal, McMillan LLP David Sausen, Tax Partner, Kaye Scholer LLP Compliance

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) Foreign Account Tax Compliance Act (FATCA) GUIDANCE NOTES: APPLICATION OF FATCA TO COLLECTIVE INVESTMENT VEHICLES Issued by Inland Revenue, New Zealand 30 July 2014 Version 1.0 Please direct all comments

More information

PRESENTATION ON THE FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA) FOR CONSULTATIONS WITH THE INDUSTRY

PRESENTATION ON THE FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA) FOR CONSULTATIONS WITH THE INDUSTRY PRESENTATION ON THE FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA) FOR CONSULTATIONS WITH THE INDUSTRY Prepared for the Meeting with ECCU Non-Bank Financial Institutions February 2014 EASTERN CARIBBEAN CENTRAL

More information

Below is a summary of the main issues discussed during our April 28 meeting, and our recommendations for resolving them.

Below is a summary of the main issues discussed during our April 28 meeting, and our recommendations for resolving them. Donna J. Fisher Senior Vice President Tax, Accounting & Financial Management (202) 663-5318 DFisher@aba.com September 11, 2015 Theodore D. Setzer International Business Compliance - Foreign Payments Program

More information

The IRS Issues Final FATCA Regulations

The IRS Issues Final FATCA Regulations The IRS Issues Final FATCA Regulations On January 17, 2013, the Internal Revenue Service (IRS) released 544 pages of final regulations implementing the provisions of the Foreign Account Tax Compliance

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) Foreign Account Tax Compliance Act (FATCA) What We Know and Don t Know Nicole Tanguy, Citi Phil Garlett, Burt, Staples & Maner LLP 11-12 July 2011 What is FATCA? The State of the Law New Chapter 4 of the

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) Foreign Account Tax Compliance Act (FATCA) What We Know and Don t Know Nicole Tanguy, Citigroup Inc. November 30, 2011 What is FATCA? The State of the Law New Chapter 4 of the Internal Revenue Code (IRC)

More information

Analysis of Final FATCA Regulations

Analysis of Final FATCA Regulations Analysis of Final FATCA Regulations January 2013 kpmg.com For more information about the FATCA regulations, contact a tax professional with KPMG LLP: General information: Laurie Hatten-Boyd 206-913-4489

More information

ACTION: Notice of proposed rulemaking and notice of public hearing. SUMMARY: This document contains proposed regulations under chapter 4 of

ACTION: Notice of proposed rulemaking and notice of public hearing. SUMMARY: This document contains proposed regulations under chapter 4 of [4830-01-p] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1 and 301 [REG-121647-10] RIN 1545-BK68 Regulations Relating to Information Reporting by Foreign Financial Institutions and

More information

Private Equity Alert

Private Equity Alert March 1, 2013 Private Equity Alert Final FATCA Regulations Released Impact on Private Investment Funds On January 17, 2013, the US Treasury and the IRS released final regulations under the Foreign Account

More information

FATCA Online. Registration. User Guide. November 2015. Foreign Account Tax Compliance Act

FATCA Online. Registration. User Guide. November 2015. Foreign Account Tax Compliance Act Foreign Account Tax Compliance Act FATCA Online Registration User Guide November 2015 Publication 5118 (Rev.11-2015) Catalog Number 65265H Department of the Treasury Internal Revenue Service www.irs.gov

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) Foreign Account Tax Compliance Act (FATCA) Introduction As a global financial services organisation, it is necessary for Standard Bank to comply with the laws and regulations of many different authorities,

More information

The Treasury Department and IRS Release Updates to Final FATCA Regulations as well as Coordination Regulations Closing the distance

The Treasury Department and IRS Release Updates to Final FATCA Regulations as well as Coordination Regulations Closing the distance The Treasury Department and IRS Release Updates to Final FATCA Regulations as well as Coordination Regulations Closing the distance Global Financial Services Industry Deloitte s initial analysis in response

More information

Global IRW Newsbrief Information reporting and withholding (IRW)

Global IRW Newsbrief Information reporting and withholding (IRW) www.pwc.com Global IRW Newsbrief Information reporting and withholding (IRW) February 27, 2012 The new proposed FATCA regulations: Overview On October 27, 2009, members of the U.S. Senate Finance Committee

More information

ACFCS FATCA One Day Seminar June 21, 2013. Role and Application of Technology in FATCA

ACFCS FATCA One Day Seminar June 21, 2013. Role and Application of Technology in FATCA ACFCS FATCA One Day Seminar June 21, 2013 Role and Application of Technology in FATCA Chris Corrie VP, Global Trade and Treasury D&B Washington, DC Jerry Khan Senior Manager, Tax KPMG New York, NY Combating

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) February 13, 2014 Spanish Chinese Russian Foreign Account Tax Compliance Act (FATCA) Introduction to FATCA and IGAs The Foreign Account Tax Compliance Act (FATCA) is a US law enacted in 2010 as part of

More information

Key Aspects of the FATCA Regime

Key Aspects of the FATCA Regime TAX CLIENT PUBLICATION May 2012... Key Aspects of the FATCA Regime... The US withholding and information reporting regime under the Foreign Account Tax Compliance Act of 2010 ( FATCA ), 1 when implemented,

More information

FATCA Regs Come Up Short For P&C Insurance Industry

FATCA Regs Come Up Short For P&C Insurance Industry Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com FATCA Regs Come Up Short For P&C Insurance Industry

More information

Simplified Instructions for Completing a Form W-8BEN-E

Simplified Instructions for Completing a Form W-8BEN-E Simplified Instructions for Completing a Form W-8BEN-E For Non-Financial Institutions Only Updated April 2015 Circular 230 Disclaimer: Any tax advice contained in this communication is not intended or

More information

IRAS e-tax Guide. Compliance Requirements of the Singapore-US Intergovernmental Agreement on Foreign Account Tax Compliance Act

IRAS e-tax Guide. Compliance Requirements of the Singapore-US Intergovernmental Agreement on Foreign Account Tax Compliance Act IRAS e-tax Guide Compliance Requirements of the Singapore-US Intergovernmental Agreement on Foreign Account Tax Compliance Act Published by Inland Revenue Authority of Singapore Published on 17 Mar 2015

More information

Foreign Account Tax Compliance Act

Foreign Account Tax Compliance Act www.pwc.co.za Foreign Account Tax Compliance Act 7t h March 2012 An overview The Foreign Account Tax Compliance Act provisions which were included in the Hiring Incentives to Restore Employment ( HIRE

More information

David Weisner. Carolina Caballero. Today s Speakers. U.S. Tax Counsel for Asia Pacific. Citi

David Weisner. Carolina Caballero. Today s Speakers. U.S. Tax Counsel for Asia Pacific. Citi 1 2 Understanding FATCA David Weisner, U.S. Tax Counsel for Asia Pacific, Citi Carolina Caballero, Product Risk and Regulatory Strategy Manager, Clearing and FI Payments, Citi Treasury and Trade Solutions

More information

FATCA and Insurance. Ninth Annual International Insurance Training Program

FATCA and Insurance. Ninth Annual International Insurance Training Program Ninth Annual International Insurance Training Program FATCA and Insurance Stewart Kasner, Baker & McKenzie LLP, Miami Lyubomir Georgiev, Baker & McKenzie Zurich Four Points by Sheraton Zurich, Switzerland

More information

FATCA Documentation and Due Diligence

FATCA Documentation and Due Diligence FATCA Documentation and Due Diligence Seminar on U.S. Taxation of International Banks Sponsored by the Institute of International Bankers June 19, 2012 E.A. (Lisa) Chippindale Karan Mosley Humberto Reboredo

More information

Facilitators Michael Miles Phil Ferrari

Facilitators Michael Miles Phil Ferrari Product Tax Seminar September 20 21, 2012 Washington, DC 1B: FATCA for Actuaries Chair Howard Stecker Facilitators Michael Miles Phil Ferrari What Actuaries Need to Know About The Impact of FATCA on Insurance

More information

Foreign Account Tax Compliance Act ( FATCA )

Foreign Account Tax Compliance Act ( FATCA ) May 2011 Foreign Account Tax Compliance Act ( FATCA ) www.steptoe.com Table of Contents Overview Definition of Foreign Financial Institution ( FFI ) FFI Agreement with IRS Preexisting Individual Accounts

More information

IIB Seminar on U.S. Taxation of International Banks FATCA FFI Agreements and Form W-8 Series Instructions

IIB Seminar on U.S. Taxation of International Banks FATCA FFI Agreements and Form W-8 Series Instructions IIB Seminar on U.S. Taxation of International Banks FATCA FFI Agreements and Form W-8 Series Instructions June 17-18, 2013 Laurie Hatten-Boyd, KPMG LLP Denise Hintzke, Deloitte Tax LLP Yaron Reich, Cleary

More information

FATCA for Multinational Companies

FATCA for Multinational Companies FATCA for Multinational Companies Alan J. Schwartz February 27, 2015 www.mwe.com Boston Brussels Chicago Düsseldorf Frankfurt Houston London Los Angeles Miami Milan Munich New York Orange County Paris

More information

The Impact of FATCA on Mutual Funds and other Regulated, Open-ended Funds Closing the distance

The Impact of FATCA on Mutual Funds and other Regulated, Open-ended Funds Closing the distance The Impact of FATCA on Mutual Funds and other Regulated, Open-ended Funds Closing the distance Global Financial Services Industry Overview The Treasury Department and the Internal Revenue Service ( IRS

More information

FATCA Final Regulations: Definitions List

FATCA Final Regulations: Definitions List FATCA Final Regulations: Definitions List By Craig Cohen Chapter 4 of the Internal Revenue Code and the Treasury regulations thereunder commonly known as the Foreign Account Tax Compliance Act, or FATCA

More information

Tax Group Client Alert

Tax Group Client Alert Tax Group Client Alert For Beijing Frankfurt Hong Kong London Los Angeles Munich New York São Paulo Singapore Tokyo Washington, DC FATCA 2.0 FOR FUNDS AND SECURITIZATION VEHICLES Introduction On February

More information

WEBER METALS, INC. Vendor Application Form (Foreign)

WEBER METALS, INC. Vendor Application Form (Foreign) WEBER METALS, INC. Vendor Application Form (Foreign) Company Name Address (if different from W-8) Street: City County Zip Code Country Phone # Fax # (Opt.) Contact Information Contact Email Tax ID Number

More information

Frequently Asked Questions (FAQ) FATCA

Frequently Asked Questions (FAQ) FATCA Frequently Asked Questions (FAQ) FATCA Table of Contents General... 3 What is FATCA?... 3 What is the purpose of FATCA?... 3 When does FATCA begin?... 3 Who is impacted by FATCA?... 3 What information

More information

Withholding of Tax on Nonresident Aliens and Foreign Entities

Withholding of Tax on Nonresident Aliens and Foreign Entities Department of the Treasury Internal Revenue Service Publication 515 Cat. No. 15019L Withholding of Tax on Nonresident Aliens and Foreign Entities For use in 2013 Contents What's New... 1 Reminders... 2

More information

Updated Guidance Notes for the Implementation of FATCA in Ireland Released

Updated Guidance Notes for the Implementation of FATCA in Ireland Released Updated Guidance Notes for the Implementation of FATCA in Ireland Released On 1 October 2014, the Irish Revenue Commissioners released updated Guidance Notes on the implementation of FATCA in Ireland (

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) www.pwc.com Foreign Account Tax Compliance Act (FATCA) Treasury Regulations 1.1471-1.1474 Incorporating updates through 1 July 2014 Ver. 1.2 1 August 2014 No claim to original U.S. Government works This

More information

Global FS Tax Newsflash How do the proposed FATCA regulations impact Insurers?

Global FS Tax Newsflash How do the proposed FATCA regulations impact Insurers? Global FS Tax Newsflash How do the proposed FATCA regulations impact Insurers? February 20, 2012 How do the proposed FATCA regulations impact Insurers On February 8th, the highly anticipated proposed regulations

More information

Agreement Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA

Agreement Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA Agreement Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA Whereas, Switzerland and the United States of America ( United States, each, a Party

More information

FATCA Frequently Asked Questions

FATCA Frequently Asked Questions FATCA Frequently Asked Questions FATCA overview 1. What is FATCA? 2. What is the impact of FATCA? 3. How do I know if I am affected? 4. When will the FATCA legislation become effective? 5. Is HSBC the

More information

Flash News. Why should non-financial entities care about FATCA?

Flash News. Why should non-financial entities care about FATCA? www.pwc.lu/fatca Flash News Why should non-financial entities care about FATCA? Published in Kluwer - ACE Comptabilité, fiscalité, audit, droit des affaires au Luxembourg, 2014/6 17 July 2014 In 2010,

More information

Spotlight on the US. Christopher Brown US Tax Desk, KPMG In the UK

Spotlight on the US. Christopher Brown US Tax Desk, KPMG In the UK Spotlight on the US Christopher Brown US Tax Desk, KPMG In the UK 24 June 2016 Agenda 1 2 3 4 5 6 7 8 FATCA: An overview Definition of FIs under FATCA FATCA reportable accounts and account holders Remediation

More information

Agreement 1 Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA

Agreement 1 Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA Agreement 1 Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA Whereas, Switzerland and the United States of America ( United States, each, a

More information

US Foreign Account Tax Compliance Act Intergovernmental Agreement. Frequently Asked Questions

US Foreign Account Tax Compliance Act Intergovernmental Agreement. Frequently Asked Questions US Foreign Account Tax Compliance Act Intergovernmental Agreement Frequently Asked Questions This document aims to provide background information regarding the intergovernmental agreement ( IGA ) to be

More information

FATCA Q & A Issue 12 Luxembourg, April 15thMay 6th, 2014

FATCA Q & A Issue 12 Luxembourg, April 15thMay 6th, 2014 Q & A Issue 12 Luxembourg, April 15thMay 6 th, 2014 Important This Q&A document was prepared by ALFI's implementation working groups for the U.S. Foreign Account Tax Compliance Act (). The working groups

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) Foreign Account Tax Compliance Act (FATCA) FATCA REGISTRATION GUIDANCE NOTES Issued by Inland Revenue, New Zealand 30 July 2014 Version 1.4 [Note: These Guidance Notes replace version 1.3, dated 13 January

More information

Guidance for companies, trusts and partnerships on completing a self-certification form

Guidance for companies, trusts and partnerships on completing a self-certification form Guidance for companies, trusts and partnerships on completing a self-certification form In order to combat tax evasion by both individuals and businesses, the UK and many other countries have entered into

More information

FATCA Q & A REPORTING AND WITHHOLDING

FATCA Q & A REPORTING AND WITHHOLDING FATCA Q & A REPORTING AND WITHHOLDING Issue 1 Luxembourg, June 26th, 2015 Important This Q&A document was prepared by ALFI's implementation working groups for the U.S. Foreign Account Tax Compliance Act

More information

Flash News Luxembourg Financial Institutions:

Flash News Luxembourg Financial Institutions: www.pwc.lu/fatca Flash News FATCA in Luxembourg: official guidelines published 10 August 2015 The law adopting the US-Luxembourg Intergovernmental Agreement (the IGA) under the terms of which the US Foreign

More information

F.A.T.C.A. in a Nutshell: Questions and Answers to Tickle the Fancy of a Compliance Officer 1 By Fabien Gaglio and Stanley C.

F.A.T.C.A. in a Nutshell: Questions and Answers to Tickle the Fancy of a Compliance Officer 1 By Fabien Gaglio and Stanley C. F.A.T.C.A. in a Nutshell: Questions and Answers to Tickle the Fancy of a Compliance Officer 1 By Fabien Gaglio and Stanley C. Ruchelman The following F.A.Q. provides a general overview of the Foreign Account

More information

FOREIGN ACCOUNT TAX COMPLIANCE ACT ( FATCA ): COMPLIANCE TO ELIMINATE WITHHOLDING TAX. November 19, 2013

FOREIGN ACCOUNT TAX COMPLIANCE ACT ( FATCA ): COMPLIANCE TO ELIMINATE WITHHOLDING TAX. November 19, 2013 FOREIGN ACCOUNT TAX COMPLIANCE ACT ( FATCA ): COMPLIANCE TO ELIMINATE WITHHOLDING TAX November 19, 2013 MICHAEL HIRSCHFELD DECHERT LLP (212) 698-3635 michael.hirschfeld@dechert.com 12116187v1 1 FATCA Overview

More information

www.pwc.com/us/fatca Ready, set, FATCA: How the new rules will affect insurers, and why early action is the best policy July 2011

www.pwc.com/us/fatca Ready, set, FATCA: How the new rules will affect insurers, and why early action is the best policy July 2011 www.pwc.com/us/fatca Ready, set, FATCA: July 2011 How the new rules will affect insurers, and why early action is the best policy Introduction In March of 2010, the Foreign Account Tax Compliance Act (FATCA)

More information

Gearing Up for FATCA and Dodd-Frank: Next Steps for Trade Finance

Gearing Up for FATCA and Dodd-Frank: Next Steps for Trade Finance Gearing Up for FATCA and Dodd-Frank: Next Steps for Trade Finance City of London Club, London 25 February 2014 Douglas S. Stransky dstransky@sandw.com 617-338-2437 Agenda Repeal of FATCA Background of

More information

Implementation of The International Tax Compliance (United States of America) Regulations 2013. Guidance Notes

Implementation of The International Tax Compliance (United States of America) Regulations 2013. Guidance Notes Implementation of The International Tax Compliance (United States of America) Regulations 2013 Guidance Notes 14 August 2013 1 Guidance Contents 1. Background 1.1 The purpose of these Guidance notes 1.2

More information

VEDDERPRICE Chicago New York Washington, DC London San Francisco Los Angeles. FATCA for Private Funds: Key Considerations

VEDDERPRICE Chicago New York Washington, DC London San Francisco Los Angeles. FATCA for Private Funds: Key Considerations VEDDERPRICE Chicago New York Washington, DC London San Francisco Los Angeles August 2014 FATCA for Private Funds: Key Considerations Although the Foreign Account Tax Compliance Act (FATCA) went live July

More information

Insurance Authority Workshop Foreign Account Tax Compliance Act. Abu Dhabi 28 January 2014

Insurance Authority Workshop Foreign Account Tax Compliance Act. Abu Dhabi 28 January 2014 Insurance Authority Workshop Foreign Account Tax Compliance Act Abu Dhabi 28 January 2014 Agenda q q q q q q FATCA and IGAs FATCA Timeline Focus for next 6 months US Treasury and IRS update Matters Arising

More information

Private Banking. Foreign Account Tax Compliance Act (FATCA) Entity Classification Guide

Private Banking. Foreign Account Tax Compliance Act (FATCA) Entity Classification Guide Private Banking Foreign Account Tax Compliance Act (FATCA) Entity Classification Guide Foreign Account Tax Compliance Act (FATCA) Entity Classification Guide August, 2014 Disclaimer This document is not

More information

What s News in Tax Analysis That Matters from Washington National Tax

What s News in Tax Analysis That Matters from Washington National Tax What s News in Tax Analysis That Matters from Washington National Tax FATCA and Foreign Leasing Companies The Foreign Account Tax Compliance Act ( FATCA ) imposes withholding and reporting requirements

More information

Foreign Account Tax Compliance Act ( FATCA ) How Does It Affect NFFEs and Individuals

Foreign Account Tax Compliance Act ( FATCA ) How Does It Affect NFFEs and Individuals Foreign Account Tax Compliance Act ( FATCA ) How Does It Affect NFFEs and Individuals May, 2012 2008 Venable LLP 1 agenda Overview FATCA and NFFEs FATCA and Individuals US Information Reporting for US

More information

FATCA Frequently Asked Questions (FAQs) Closing the distance

FATCA Frequently Asked Questions (FAQs) Closing the distance FATCA Frequently Asked Questions (FAQs) Closing the distance Global Financial Services Industry 1. What is FATCA? FATCA stands for the Foreign Account Tax Compliance Act. It colloquially refers to provisions

More information

TECHNICAL EXPLANATION OF THE FOREIGN ACCOUNT TAX COMPLIANCE ACT OF 2009

TECHNICAL EXPLANATION OF THE FOREIGN ACCOUNT TAX COMPLIANCE ACT OF 2009 TECHNICAL EXPLANATION OF THE FOREIGN ACCOUNT TAX COMPLIANCE ACT OF 2009 Prepared by the Staff of the JOINT COMMITTEE ON TAXATION October 27, 2009 JCX-42-09 CONTENTS INTRODUCTION... 1 Page I. INCREASED

More information

Cayman Islands Financial Account Reporting for Investment Funds What Must Be Done, By When?

Cayman Islands Financial Account Reporting for Investment Funds What Must Be Done, By When? ealert November 2014 Cayman Islands Financial Account Reporting for Investment Funds What Must Be Done, By When? The Cayman Islands currently has in place an intergovernmental agreement (IGA) with each

More information

Foreign Account Tax Compliance Act (FATCA) Entity Questionnaire

Foreign Account Tax Compliance Act (FATCA) Entity Questionnaire SIPP ISA Dealing Junior ISA Foreign Account Tax Compliance Act (FATCA) Entity Questionnaire This form must be completed by all new entities (customers who are not individuals) as part of our account opening

More information

Whereas, the Government of the Republic of Poland is supportive of the underlying policy goal of FATCA to improve tax compliance;

Whereas, the Government of the Republic of Poland is supportive of the underlying policy goal of FATCA to improve tax compliance; Agreement between the Government of the Republic of Poland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA Whereas, the Government of the

More information

TAXATION (INTERNATIONAL TAX COMPLIANCE) (CROWN DEPENDENCY [CD]) REGULATIONS 2014 GUIDANCE NOTES. RELEASE DATE: 1 April 2014

TAXATION (INTERNATIONAL TAX COMPLIANCE) (CROWN DEPENDENCY [CD]) REGULATIONS 2014 GUIDANCE NOTES. RELEASE DATE: 1 April 2014 TAXATION (INTERNATIONAL TAX COMPLIANCE) (CROWN DEPENDENCY [CD]) REGULATIONS 2014 GUIDANCE NOTES RELEASE DATE: 1 April 2014 Note : These draft Guidance Notes dated 1 April 2014 have been revised to reflect

More information

WHITE PAPER. Impact of FATCA on Client Onboarding Achieve FATCA compliance with effective, result-oriented IT and operational changes.

WHITE PAPER. Impact of FATCA on Client Onboarding Achieve FATCA compliance with effective, result-oriented IT and operational changes. WHITE PAPER Impact of FATCA on Client Onboarding Achieve FATCA compliance with effective, result-oriented IT and operational changes Abstract In March 2010, the Foreign Account Tax Compliance Act (FATCA)

More information

Version 3.0 (29.07.2014) Table of Contents

Version 3.0 (29.07.2014) Table of Contents Guidelines for the implementation of the FATCA Agreement and the FATCA Regulations in Malta issued in terms of Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta) Version 3.0 (29.07.2014)

More information

F O R E I G N A C C O U N T T A X C O M P L I A N C E A C T : C U R R E N T D E V E L O P M E N T S

F O R E I G N A C C O U N T T A X C O M P L I A N C E A C T : C U R R E N T D E V E L O P M E N T S S T R I C T L Y P R I V A T E A N D C O N F I D E N T I A L F O R E I G N A C C O U N T T A X C O M P L I A N C E A C T : C U R R E N T D E V E L O P M E N T S J.P. Morgan Corporate & Investment Bank Presented

More information

BENEFITS & COMPENSATION INTERNATIONAL TOTAL REMUNERATION AND PENSION INVESTMENT

BENEFITS & COMPENSATION INTERNATIONAL TOTAL REMUNERATION AND PENSION INVESTMENT BENEFITS & COMPENSATION INTERNATIONAL TOTAL REMUNERATION AND PENSION INVESTMENT Proposed IRS Regulations Exempt Some Non-US Retirement Plans from FATCA David W. Powell and Anubhav Gogna David Powell is

More information

FATCA for non-financial companies What you don't know may hurt you

FATCA for non-financial companies What you don't know may hurt you FATCA for non-financial companies What you don't know may hurt you Anthony Martirano Jr., Deloitte Tax LLP December 6, 2012 FATCA overview FATCA aims to identify U.S. persons trying to avoid U.S. tax obligations

More information

Guide to completing W-8BEN-E entity US tax forms

Guide to completing W-8BEN-E entity US tax forms Guide to completing W-8BEN-E entity US tax forms Applicable to Companies, Trusts, Self-Managed Superannuation Funds and Deceased Estates Macquarie Wrap 1 macquarie.com Contents 1 General information 01

More information

FATCA and KYC Similar yet different

FATCA and KYC Similar yet different www.pwc.com FATCA and KYC Similar yet different November 12, 2012 FATCA extends customer due diligence and reporting requirements well beyond what is typically performed for KYC purposes. Background While

More information